- 8 - On the evidence before us, we conclude Lora did not have actual knowledge of the underlying circumstances resulting in the disallowance of the deductions related to the equipment leasing partnership investments. Isaac sought out these equipment leasing partnership investments. Lora was a homemaker, mother, and part-time student of interior decorating. Lora was only generally familiar with the existence of the investments in the equipment leasing partnerships. Isaac invested in the equipment leasing partnerships in his own name, and Isaac, independently of Lora, used the information relating to those investments in preparation of the joint income tax returns. Lora relied on Isaac’s professional experience as a C.P.A. in signing the joint income tax returns. Based on all the facts before us, we agree with Lora and respondent that Lora did not have actual knowledge of the underlying equipment leasing partnership transactions giving rise to the stipulated deficiencies, and, therefore, that Lora is entitled to relief from joint liability under section 6015(c) for the years in issue. Herein, we need not address arguments regarding whether Lora is entitled to relief under section 6015(b). Other arguments made by petitioners that are not specifically addressed have been considered and rejected.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011